On 12 January 2023, the Central Bank of Nigeria (“CBN”) issued its Guidance on Ultimate Beneficial Owners of Legal Persons and Legal Arrangements (“the Guidance”) with the aim of helping Financial Institutions (“FIs”) identify and verify the beneficial owners of corporate vehicles in line with anti-money laundering and anti-terrorism financing laws and regulations.

Primarily, the Guidance was issued due, among others, to an upsurge in the use of corporate vehicles to shroud the proceeds of crimes.

We anticipate that its implementation by FIs will lead to a heightened assessment of ML/TF/PF risks associated with corporate vehicles.

This commentary highlights the key provisions of the Guidance.